Showing posts with label Edison. Show all posts
Showing posts with label Edison. Show all posts

Sunday, March 30, 2014

SCE Cited For Major Nuclear Related Safety Violation At San Onofre

Get SCE Out of San Onofre
Background: NRC Spent Fuel Pool Cooling Requirements:

“Each licensee shall develop and implement guidance and strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire ….”

The San Onofre spent fuel cooling fire protection plan in the event of a large fire and/or explosion hinges on the expertise and staffing of the on-sight San Onofre Fire Department.

Since the San Onofre Fire Department and Emergency Planning Personnel Staffing was reduced to a skeleton crew without prior approval from the NRC after a full and proper evaluation, the existing fire plan is now outdated and unrealistic in event of a large fire or explosion.

A Spent Fuel Pool Cooling Accident, in case of a large fire or explosion without adequate and demonstrated mitigation measures is a MAJOR Nuclear Safety Concern for all the millions of Southern Californians living within the 10 Mile Emergency Protection Zone.  Remember Fukushima's triple meltdowns occurred because of a failure to keep their reactors cool after the big earth quake and tsunami which occurred on 03/11/11.


Last Friday, the NRC cited SCE, the operator of San Onofre's nuclear power plant for violating NRC rules by failing to get approval before eliminating 39 emergency-response jobs after the plant closed last year.

Historically, NRC Region IV has had the habit of citing Southern California Edison with only low level violations, even if the violations were actually severe violations.  This cozy relationship was a contributing factor in the radioactive leak that resulted in the early decommissioning of San Onofre Units 2 & 3 and the loss of billions of dollars to SoCal ratepayers that could have been prevented, if the NRC had enforced the Federal Regulations as written.  This type of safety enforcement is not good for Californians or the NRC.  Now a serious review/investigation and proper action/fines are required by the NRC and its Commissioners, to assure Nuclear Safety is maintained at San Onofre and all the other US Nuclear Power Plants.

The question the NRC should ask is, "Knowing that the SPENT FUEL POOLS MUST STILL BE KEPT COOL 24/7 no matter what, if a major earth quake occurred tonight, would San Onofre Fire Dept.'s skeleton crew be able to guarantee US that they could prevent a nuclear accident from occurring, especially since the 39 emergency-response positions that were illegally eliminated, probably cost ratepayers much less than even one still employed highly paid nuclear manager who would be home sleeping?  

The question that the CPUC should ask is, "If SEC is really interested in safety as they keep telling us, what is the reasonableness of continually cutting corners on those that actually insure our safety, while at the same time retaining other highly paid nuclear Staff?
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Saturday, June 22, 2013

The $742 Million Question:

The $742 Million Question

Who should pay for the extra Decommissioning money, not yet collected?

Since the operators of San Onofre made the financial decision to shut it down prematurely, all decommissioning fees not already collected for Units 2 and 3 by 01/31/12, should be paid by the operators of San Onofre, not ratepayers!


Also the California Public Utilities Commission should required SCE put the Decommissioning of San Onofre out for public bid, instead of just giving the mega billion dollar job to SCE. California ratepayers cannot afford a sole source bid when so many International Companies with nuclear expertise are looking for work.


A public bidding process will save California ratepayers huge amounts of money, money which should not end up in SCE's shareholders pockets. This single project has the potential to jump start our economy, we cannot allow the CPUC to short circuit our states bidding process by not putting this job out for bid!


   Decommissioning Costs as of 1/1/2012
SONGS 1     $ Million
SONGS 2 $ Million
SONGS 3 $ Million
  Radiological Costs
183.3
1,273.6
1,262.4
            Site Restoration
10.7
417.0
535.5
  Fuel Storage (Including ISFSI Decommissioning)
11.2
385.3
368.3
  Estimated Total Budget 2009 (See Note 2)
N/A
1,791
1,868
      Total Collected 10/31/12  (See Note 1)
291.4
1,638.1
1,865.4
    Total Projection 1/1/2012
205.2
2,079.5
2,166.2
Estimated Loss Due To Poor RSG Design/Operation
           86.2   Previously   Overbilled
        441.4           Shortfall
        300.8              Shortfall

  1. SCE  Letter to NRC (2012) https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?docId=0BweZ3c0aFXcFNHF2ZDVncy1GM0U
  2. SCE Testimony to CPUC (2009) https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?docId=0BweZ3c0aFXcFYlhqWHVQbEYyVkU
Background

The purpose of the Nuclear Decommissioning Trust Funds is to mitigate for ratepayers the high cost of decommissioning nuclear power plants at the end of their lives by collecting reasonable fees over a long period of time. The CPUC directs the investor owned utilities to collect a regular Decommissioning fee on customers’ monthly electric bills for Edison and SDG&E’s San Onofre Plant (30 years old) and PG&E’s Diablo Canyon Plant (28 years old). The expected life of a nuclear power plant is 40 years.

$5.2 billion of ratepayer collection is currently invested with the Trust Funds.

At current liquidation value, combined Decommissioning Trust Funds are ~90% funded. The Trust Funds are currently invested in equities (60%) and investment grade fixed income securities (40%). D.87-05-062 established nuclear decommissioning trusts for funding future decommissioning of the utilities’ nuclear units. Each nuclear plant has decommissioning trusts and a committee that oversees the trust fund; Under Public Utilities Code § 8326, SCE is required to provide a decommissioning cost estimate that includes, among other things,

an estimate of the costs of decommissioning, and

a description of changes in regulation, technology, and economics affecting the estimate of costs.

As SCE explains, and as TURN’s witness Lacy acknowledges, the costs to decommission a nuclear facility include the costs to

store the spent fuel onsite or offsite until it is removed by the DOE;

remove residual radioactivity from the site, including from the spent fuel storage facility, to levels required to terminate the NRC license and to release the site for unrestricted use; and

remove non-radiological structures, systems, and components as required to leave the site in a safe condition, or as otherwise mandated by the state or the site owner.

The Utilities project that they will perform the actual decommissioning in three phases.

During Phase I, the Utilities will decontaminate, dismantle, and dispose of the units and the site common facilities. The Utilities will also continue to maintain the integrity and safety of the spent fuel while it remains on the SONGS site. The Utilities will maintain spent fuel in wet storage in spent fuel pools until it can be safely transferred to the SONGS 2 & 3 Independent Spent Fuel Storage Installation (ISFSI) or removed from the site by the U.S. Department of Energy (DOE). To safely store fuel in wet storage, the Utilities must maintain each plant system required for spent fuel pool operation until the fuel is removed. The Utilities will drain, de-energize, and secure all other plant systems. After the SONGS 2 & 3 spent fuel pools are empty, the Utilities will decommission the pools and their associated support structures and systems. The Utilities assume that by the time the SONGS 2 & 3 fuel has cooled sufficiently to be removed from the spent fuel pools, the DOE will have removed enough SONGS 2 & 3 fuel from the SONGS site that it will not be necessary to further expand the ISFSI pads or to construct additional Advanced Horizontal Storage Modules (ASHM) to accommodate that fuel.

During Phase II, the Utilities will monitor the ISFSI until the DOE removes the last spent fuel from the site, which is assumed to occur by 2051 based on studies developed from the DOE Acceptance Priority Ranking & Annual Capacity Report (DOE/RW-0567), dated July 2004.

During Phase III, the Utilities will dismantle and dispose of the ISFSI, all remaining site common facilities, and the remaining structural foundations; terminate the NRC licenses; and complete the final site restoration work.

Note: The Utilities do not own the site upon which the SONGS facility is located. Instead, they are authorized to use the site under several lease contracts and grants of easement from the U.S. Department of the Navy and the California State Lands Commission. To terminate these agreements, the Utilities are required to remove all improvements they installed or constructed on the site, except as agreed by the lessors/grantors, return the site to a condition satisfactory to the grantor, and return the site to the lessors/grantors.

Monday, April 8, 2013

Why fatigue damage will stop the NRC from allowing Unit 2 to restart






FATIGUE DAMAGE TO SONGS STEAM GENERATORS
J. Hopenfeld 

Provided to the “DAB Safety Team” as additional explanation of the fatigue damage to SONGS steam generators which was discussed in a report by the author and was submitted to the California Public Utility Commission on March 29, 2013

Note: Links to these documents are listed below 

SCE/MHI made a mistake in their stress analysis, which directly impacts the safety of restarting Unit 2.  When the error is corrected, the result clearly shows that Unit 2 has already used up its allowed fatigue life and is not fit for service any longer.  This means that if Unit 2 is restarted at any power level an abrupt pressure change such as inadvertent closing or opening of a valve or a steam line break could lead to a sudden tube ruptures.   The ASME code and NRC regulations do not permit safety components to operate when their fatigue life has been exhausted.

The source of MHI’s error resulted from how they calculated the increase in the local stress at geometrical discontinuities  (notches), which are formed when two metal surfaces come in contact during vibration.  Since the worn surfaces of the tubes inside the steam generators cannot be seen, MHI made two key assumptions, which are inconsistent with the observation that both the tube and the supporting bar are worn into each other.  First, MHI assumed that the ASME endurance limit could be applied directly to the notched tube surfaces.  Since it is commonly known that surface roughness significantly reduces fatigue life and since the ASME data is for smooth polished surfaces, this assumption would underestimate the amount of fatigue damage.  Second, when using the Peterson chart, MHI assumed unrealistically large fillet radius and consequently derived a low concentration stress factor.  Large radii would decrease the local stress and cause the tube to fail at a higher stress thereby increasing its fatigue life.  Only by using these two, arbitrary non-conservative, assumptions was MHI able to conclude that Unit 2 did not suffer any fatigue damage.

As depicted in the MHI drawings the support bar and the tube form a sharp discontinuity at the contacting surface, therefore the appropriate geometry for calculating the stress concentration is an abrupt geometry change (very small radii), not a large radius shoulder fillet that was assumed by MHI.  When a correction is made to account for the sharp notch, the corrected stress indicates  (see Figure 1 below) that the tubes have used up their fatigue life during the first cycle of operation.  Structures with sharp notches can fail catastrophically when subjected to high cycle vibrations.  (MHI redacted their assumption so the exact value of the radius they used is unknown.)

 The loss of fatigue life is a major defect in the tube material; NRC regulations 10CFR50, Appendix B, Criterion 16 specify that for a licensee to maintain his operating license, such non-conformance must be promptly identified and corrected.   The licensee must assure that “corrective action (is) taken to preclude repetition.  NRC’s General Design Criteria 4 and 10CFR50 Appendix A also specify that steam generator tubes must be able to “ accommodate the effects of loss of coolant accidents “ The fact that the NRC has not already raised these issues in any of their  “Requests for Additional Information, RAIs” indicates that the NRC would be ignoring its own regulations if it allows SCE to restart Unit 2.

 In Summary: The SCE request for approval to operate Unit 2 at 70 % power for 150 days provided no explanation for the selection of this inspection interval.  The absence of such explanation and the absence of an indication of the actions that would follow demonstrate the unreliability of SCE entire assessment of restarting Unit 2.  Edison did not specify pass/fail criteria for the tubes during the outage inspection.  Given the fact that fatigue damage does not lend itself to detection, SCE request is unacceptable and should be rejected. 
  

Wednesday, April 3, 2013

NRC: The Good, The Bad and the Ugly


NRC: The Good, The Bad and the Ugly


... and why it is unsafe To restart San Onofre






A GOOD NRC enforcement example:

Davis-Besse Nuclear Power Station is a nuclear power plant in Oak Harbor, Ohio. On March 5, 2002, maintenance workers discovered that corrosion had eaten a football-sized hole into the reactor vessel head of the Davis-Besse plant. Corrosion had been clogging the plant’s filters for months, requiring repeated filter replacement, but the cause was not investigated until after a worker leaned against a control rod drive mechanism, and it toppled over. Although the corrosion did not lead to an accident, this was considered to be a serious nuclear safety incident. Some observers have criticized the NRC’s Commission work as an example of regulatory capture [See Note 1] and the NRC has been accused of doing an inadequate job by the Union of Concerned Scientists.  The Nuclear Regulatory Commission kept Davis-Besse shut down until March 2004, so that FirstEnergy was able to perform all the necessary maintenance for safe operations. The NRC imposed its largest fine evermore than $5 million—against FirstEnergy for the actions that led to the corrosion. The company paid an additional $28 million in fines under a settlement with the U.S. Department of Justice. The NRC closely monitored FENOC’s response and concluded in September 2009 that FENOC met the conditions of the 2004 order. From 2004 through 2009 the NRC reviewed 20 independent assessments conducted at the plant and verified the independent assessors’ credentials. The agency also conducted its own inspections and reviewed FENOC’s reactor vessel inspections conducted in early 2005. NRC inspectors paid particular attention to the order’s focus on safety culture and safety conscious work environment to ensure there were no new signs of weakness. The NRC task force concluded that the corrosion, occurred for several reasons:

·    NRC, Davis-Besse and the nuclear industry failed to adequately review, assess, and follow up on relevant operating experience at other nuclear power plants;
·    Davis-Besse failed to ensure that plant safety issues received appropriate attention; and
·    NRC failed to integrate available information in assessing Davis-Besse’s safety performance.


A BAD NRC enforcement example:

At San Onofre by Region IV and the NRC: The papers shown below have been obtained from Public Domain written by Dr. Joram Hopenfeld and a former SONGS Employee based on his investigation of the steam generator issues, review of the plant data and discussions with several Key SONGS Insiders. These papers confirm that Southern California Edison wants to restart unsafe Unit 2 nuclear reactor at 70% power under false pretenses, just for profits, and as an unapproved risky experiment by subverting the NRC and Federal regulatory process.  The true Root Cause (See Note 2) of the unprecedented tube-to-tube wear in Unit 3 has NOT been officially established, as required by NRC Confirmatory Letter Action 1 for restarting the defectively designed and degraded Unit 2.  NRC has not even completed their review of Unit 2 Return to Service Reports, nor have they finished Special Unit 2 Tube Inspections, nor have they (publicly?) reviewed SCE’s Response to NRC’s Requests for Additional Information (RAIs).
NOTE: NO FINES ARE MENTIONED - WHY?


An UGLY NRC enforcement example?:

Now, SCE wants the NRC to approve a new shady License Amendment, undermining public safety and they want it done without the involvement of Public Safety Experts, Attorneys and/or Citizens/Ratepayers.  After the review of the Mitsubishi Root Cause Evaluation and the Draft SCE License Amendment, it is crystal clear that the NRC needs to follow the example of their own enforcement at David Besse together with the lessons learned from Fukushima, when it comes to NOT approving this new Shady License Amendment for restarting San Onofre Unit 2’s defectively designed and degraded replacement steam generators.  In light of the unanticipated/unprecedented tube leakage at San Onofre Unit 3, the health and safety, along with the economic concerns/objections of 8.4 million Southern Californians’ MUST OVERRIDE and PREVENT the restarting of Unit 2 at ANY power level.  In a Democratic Society, truth must prevail over profit motivations, misleading propaganda of electricity service disruption and/or projected probabilistic temporary inconveniences to the public based on phony data, because America cannot afford a trillion dollar nuclear eco-disaster!

Our Safety must override SCE's profits and prevent them from restarting Unit 2.

Notes:

1: Regulatory capture occurs when a regulatory agency, created to act in the public interest, instead advances the commercial or special concerns of interest groups that dominate the industry or sector it is charged with regulating.  Regulatory capture is a form of government failure, as it can act as an encouragement for firms to produce negative externalities. The agencies are called "captured agencies".

2. Human performance errors resulting from the negative safety culture of production (profits) goals overriding public safety obligations.


=======================================================================
Additional Information:

The full DAB Safety Team's Media Alert 5 Parts:
https://docs.google.com/folder/d/0BweZ3c0aFXcFZGpvRlo4aXJCT2s/edit?pli=1&docId=15V8BD4YK0MjwUV6gPZt6ILS_lP7CpClzgnZentLfx8U

The complete five (5) part presentation, see the eight (8) titles listed below:


Thursday, March 14, 2013

San Onofre Unit 2 Retainer Bars Could Cause Massive ☢ Leakage



In an accident like a main steam line break at San Onofre, the badly designed retainers bars in Unit 2 could actually make things much worse by causing more damage to any of the 9,727 already fatigued tubes in each of its steam generators which could lead to additional leakage of highly radioactive reactor core coolant and/or cause a nuclear incident or worse a nuclear accident like Fukushima!


Radioactive Leaks and ruptures can happen without notice:





Allegation/Violations

The NRC has decided in AIT follow-up report dated 11/09/2012, “Item 3. “(Closed) Unresolved Item 05000362/2012007-03, ‘Evaluation of Retainer Bars Vibration during the Original Design of the Replacement Steam Generators” as a non-cited violation in accordance with Section 2.3.2 of the NRC’s Enforcement Policy.”  However, as shown below, SCE/MHI’s failure to verify the adequacy of the retainer bar design as required by SCE/MHI’s procedures have resulted in plugging of several hundred tubes in the brand new replacement generators. This has resulted in these violations:

1. Failure to meet NRC Chairman Standards on Nuclear Safety by SCE,
2. Failure to meet Senator Boxer’s Committee on Environment and Public Works
(EPW) Standards on Nuclear Safety by SCE,
3. Failure to enforce SCE Edison Contract Document instructions to MHI by SCE,
4. Failure to meet SONGS Technical Specifications by SCE,
5. Failure to meet general design criteria (GDC) in Appendix A, “General Design
Criteria for Nuclear Power Plants,” to 10 CFR Part 50, “Domestic
Licensing of Production and Utilization Facilities GDC 14, “Reactor
Coolant Pressure Boundary” by SCE/MHI,
6. Failure to demonstrate that Unit 2 retainer bars will maintain tube bundle
geometry at 70% power due to fluid elastic instability during a main line
steam break (MSLB) design basis event, and
7. SCE/MHI took shortcuts by avoiding the 10 CFR 50.90 License Amendment
Process under the false pretense of “like for a like” replacement steam
generator.  SCE added 377 more tubes, increased the average length of the
heated tubes and changed the thermal-hydraulic operation of the RSGs without
proper safety analysis and inadequate 10CFR 50.59 Evaluation.
This intentional action to produce more thermal megawatts out of the
RSGs compromised safety at SONGS Unit 2 due to the failure of 90
percent through wall thickness of a tube by the inadequate design of the
r
etainer bar.

Recommended Actions:

NRC San Onofre Special Panel is requested to resolve the above listed Allegations and/or Violations within 30 days of receipt of this email and prior to granting SCE’s permission to do any restart "testing" of Unit 2. Answer all allegations factually, don't just void them.
 
See Full Document:
Media Alert: San Onofre Retainer Bar Problems

Tuesday, February 12, 2013

Did Edison Submit False Info To NRC?


SAN ONOFRE: Did Edison submit false information to NRC?
Did Edison submit false information to NRC?

Friends of the Earth demands release of leaked report

Tonight NRC public meeting
 6 p.m. Pacific time, Tuesday, February 12, at Capo Beach Church, Capistrano Beach, and is accessible via a live webcast at: http://video.nrc.gov.


Southern California Edison, operator of the San Onofre nuclear reactors, appears to have submitted false information to the Nuclear Regulatory Commission, Friends of the Earth charged today. The nuclear watchdog again demanded the release of a suppressed report that two senior members of Congress say shows Edison had prior knowledge of potential design flaws in replacement steam generators that failed after less than two years of service.



In a letter to the NRC’s Petition Review Board, Friends of the Earth said the report, as described by Senator Barbara Boxer (D-Calif.) and Representative Edward Markey (D-Mass.), contradicts Edison’s declarations to the Commission last month. The utility claimed it had no prior knowledge of deficiencies in the design of the generators until they failed in January 2012.



Details of the Mitsubishi Heavy Industries report were released last week by Sen. Boxer, Chairwoman of the Committee on Environment and Public Works. She did not release the report, but in a letter to the NRC she and Rep. Markey said Mitsubishi told Edison of potential problems with the new generators, but modifications to correct the design flaws were not adopted, as Edison wanted to avoid triggering an NRC license amendment process. This would have required a more thorough and public review of the replacement program.



Friends of the Earth also demanded that the Petition Review Board must consider the document in proceedings currently underway. The Review Board, in response to a petition from Friends of the Earth, is determining whether Edison improperly failed to apply for a license amendment before installing replacement steam generators of a radically different design than was permitted under the reactors’ operating license.



“The Mitsubishi document appears to confirm our case before the Petition Review Board,” said Kendra Ulrich, nuclear campaigner at Friends of the Earth. “Edison made radical design changes while representing the steam generators as a like for like exchange and then actively chose not to address critical safety issues in order to avoid the license amendment process. Now it appears it also submitted information that is patently false. 

"The Mitsubishi report must be released immediately," said Ulrich. "The public has a right to know what Edison knew and when it knew it.”



Pressure is mounting daily for release of the document. On Friday, the NRC confirmed that it has opened an official investigation into the replacement steam generator case. Still, the Commission maintains that the Mitsubishi report is proprietary. In fact, it won’t even be on the agenda for the public meeting the NRC is holding tonight to discuss the experimental restart proposal. 

"Open disclosure and discussion of this document is critical to the public’s understanding of this controversial restart plan," said Ulrich. "This is the same corporate actor that apparently gambled on safety in the past, and they are asking the NRC to allow them to do so again."



In an editorial Sunday, The Los Angeles Times rebuked the NRC for not releasing information the public needs, and noted that the Mitsubishi report could not only be decisive in the NRC’s proceedings but in the investigation of Edison by the California Public Utilities Board. The Times said: 



Release the report so that ratepayers, who are paying the tab for the purchase of the steam generators, and the public, whose safety depends on responsible operation of the plant, can determine the truth . . . The NRC should make the document public, and soon. It might provide an important description of how Edison makes its safety decisions, and it could become a key aspect of the Public Utility Commission's inquiry into whether ratepayers should be forced to continue paying for the steam generators . . . What the public is entitled to is information about who knew what and when.


Click here to read the Friends of the Earth letter to the NRC Petition Review Board.

FOR IMMEDIATE RELEASE: February 12, 2013

CONTACT: Bill Walker(510) 759-9911, or Kendra Ulrich, (216) 571-7340


  Bill Walker
dba Deadline Now
Berkeley CA
(510) 759-9911
bw.deadline@gmail.com
Twitter: @deadlinenow
Skype: deadlinenow